Employees of the group must abide by the insider regulation stipulated by the Market Abuse Regulations of the EU and national law, and also the Company’s insider regulations based on the insider regulations of Nasdaq Helsinki Ltd. In addition to these, the Group’s insider management abides by First North Rules insider regulation, the Act on Investment Services, Financial Supervisory Authority rules and instructions, and personnel trading instructions based on the trading instructions of members of Finance Finland.
The Company maintains insider registers for each project that concern insider information. These registers list the people that have access to particular and the same insider information. A project here refers to a totality of procedures or an arrangement, confidentially prepared by the Company’s orders, that can be singled out, and which the Company regards as insider information, and has decided to postpone its publishing in accordance with its communications policy. The Company evaluates on a case-by-case basis if the procedures or arrangements under preparation can be regarded as a project.
The insiders of a project are those who take part in the preparations of the project or are otherwise aware of a confidential project, the execution of which may affect share values. The project register contains those who, based on their work or other agreement, receive inside information regarding a particular project, and other persons to which the Company gives inside information regarding a particular project (e.g. the Company’s advisers, officials, and unquoted companies acting as counterparties in corporate acquisitions).
Insider registers are not public. However, insider registers are available to the Financial Supervisory Authority for securities market supervision.
The Company’s management and people taking part in preparing financial reports that fall under the obligation of disclosure of periodic information must not on their own account or through a third party trade Privanet Group’s securities during a time period that begins 30 days before the publication of each bi-annual report, financial statement, or their advance information, and ends on the day after the publication of this information.
For people included in the project registers it is forbidden to trade the Company’s securities until the project is dissolved or made public.
In certain situations the Board may allow trading during the closed window for the management or other people under trade restrictions. When deviating from the trade restriction, it is forbidden to abuse inside information.
Register of the Company’s management and their immediate circle
The Company keeps a register of its management personnel and their immediate circle.
A manager refers to a person who is a member of the Board (and possibly a deputy member), CEO, deputy CEO, and a member of the management group.
The immediate circle of the Company’s management includes:
- a spouse, a common-law spouse, or a party in a registered relationship
- a child in the custody of a person in the Company’s management
- a relative who has been living in the same household for at least one year (at the time the business operation in question takes place); and
- a legal entity, trust or a partnership
- managed by a person who is a part of the Company’s management or has been mentioned before in sections 1, 2 or 3, or
- that is under direct or indirect orders of such a person, or
- that has been founded for the benefit of such a person or the financial interests of which largely concur with the financial interests of such a person.
The Company’s management and their immediate circle must notify the Company and the Financial Supervisory Authority of all transactions made with the Company’s securities. The report must be delivered immediately, at most three (3) business days after the transaction. The reporting duty begins when the unnetted total amount of transactions has reached a minimum of 5,000 euros in a calendar year.
The Company publishes the transactions made by the Company’s management and their immediate circle as Company news within three (3) business days of the transaction.
The Company’s industry is investment services, and the Act on Investment Services obliges subsidiaries to maintain a public insider register of the insiders and their holdings.
The following people are regarded as insiders in the subsidiaries:
- Board members and possible deputy members,
- CEO and possible deputy CEO,
- an auditing official acting as the Company’s principal auditor,
- a person who works for the Group and whose main task is to participate in providing investment services,
- a person working for the Group who otherwise regularly receives inside information regarding shares or financial instruments
- people working for the Group tasked with investment research concerning shares or financial instruments.
The insider administration of the Group is centralized to the parent Company Privanet Group Plc, and insider registers and the register of managers and their immediate circle are maintained by Euroclear Finland Ltd. The Chief Strategy Officer of the Group acts as the insider administrator. The Chief Personnel Officer of the Group is responsible for insider registers and monitoring personal transactions. The Compliance Officer monitors the appropriateness of insider administration and the personal transactions of people holding an authoritative position in the Group.
The public inner circle of Privanet Group Plc, which no longer has to be maintained since Jul 3rd, 2016 due to MAR, can be seen at the NetSire service operated by Euroclear Finland Ltd.
Go to NetSire by clicking the link below:
Insider register >>